A. Financial Architects Inc., doing business as Meyer Capital Group (the “Registrant”), is a
corporation formed on January 13, 1988 in the state of New Jersey. The Registrant
became registered as an Investment Adviser Firm in May 1989. The Registrant is
principally owned by Thomas C. Meyer. Mr. Meyer is the Registrant’s President.
B. As discussed below, the Registrant offers to its clients (individuals, business entities,
trusts, pension and profit sharing plans and charitable organizations, etc.) investment
advisory services, pension consulting services and, to the extent specifically requested by
a client, financial planning and related consulting services.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary and/or non-discretionary investment advisory
services on a fee-only basis. The Registrant’s annual investment advisory fee is based
upon a percentage (%) of the market value of the assets placed under the Registrant’s
management, generally between 0.75% and 1.00%.
Prior to engaging the Registrant to provide investment advisory services, clients are
required to enter into an Investment Advisory Agreement with the Registrant setting forth
the terms and conditions of the engagement.
Registrant provides investment advisory services specific to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objectives. Thereafter, the Registrant will allocate or
recommend that the client allocate investment assets consistent with their designated
investment objectives.
PENSION CONSULTING
Registrant acts as a pension consultant for various pension plans. Registrant first
determines the investment objectives and requirements that are appropriate for each plan
and then recommends various prospective investment alternatives for the plan’s review
and consideration including, but not limited to, mutual funds, group annuity contracts,
and/or separate account managers/programs (for approval by each plan sponsor) that best
fulfill the investment objectives within each investment category. The investment
management fee charged by separate account managers/programs is separate from, and in
addition to, Registrant’s advisory fee as set forth in the fee schedule at Item 5 below.
Prior to engaging the Registrant, the client will generally be required to enter into an
Investment Consulting Agreement with Registrant setting forth the terms and conditions
of the engagement, describing the scope of the services to be provided, the fee
arrangement, and the portion of the fee that is due from the client prior to Registrant
commencing services. The Registrant’s fee will be based on a percentage (%) of the
assets within the plan.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant may be engaged to provide financial planning and/or consulting services
(including investment and non-investment related matters, including estate planning,
insurance planning, etc.) on a stand-alone separate fee basis. Registrant’s planning and
consulting fees are negotiable, but generally range from $1,000 to $5,000 on a fixed fee
basis, and from $150 to $200 on an hourly rate basis, depending upon the level and scope
of the service(s) required and the professional(s) rendering the service(s).
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a Financial Planning Agreement with Registrant setting
forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the portion of the fee that is due from the client
prior to Registrant commencing services.
If requested by the client, Registrant may recommend the services of other professionals
for implementation purposes. The client is under no obligation to engage the services of
any such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from the
Registrant.
If the client engages any recommended professional, and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from and
against the engaged professional. At all times, the engaged licensed professional(s) (i.e.
attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible
for the quality and competency of the services provided.
It remains the client’s responsibility to promptly notify the Registrant if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Registrant’s previous recommendations and/or services.
MEYER AUTOMATED PORTFOLIO STRATEGY
Clients may choose to engage Registrant to provide investment management services
utilizing the Institutional Intelligent Portfolios™ Program, relative to investment
accounts with market values of at least $5,000 under the Meyer Automated Portfolio
Strategy (“MAPS”). Institutional Intelligent Portfolios™, is an automated, online
investment management platform for use by independent investment advisors offered by
software provider Schwab Performance Technologies (“SPT”). Through MAPS, the
Registrant offers clients a range of investment strategies we have constructed and
manage. The client’s portfolio is held in a brokerage account opened by the client at
SPT’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). The Registrant is independent
of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co or their
affiliates (together, “Schwab”).
The Registrant, and not Schwab, is the client’s investment advisor and primary point of
contact with respect to MAPS. The Registrant is solely responsible, and Schwab is not
responsible, for determining the appropriateness of MAPS for the client, choosing a
suitable investment strategy and portfolio for the client’s investment needs and goals, and
managing that portfolio on an ongoing basis.
The Registrant has contracted with SPT to provide us with the technology platform and
related trading and account management services for MAPS. This platform enables us to
make MAPS available to clients online and includes a system that automates certain key
parts of our investment process (the “System”). The System includes an online
questionnaire that helps us determine the client’s investment objectives and risk tolerance
and select an appropriate investment strategy and portfolio. Clients should note that the
Registrant will recommend a portfolio via the System in response to the client’s answers
to the online questionnaire. The client may then indicate an interest in a portfolio that is
one level less or more conservative or aggressive than the recommended portfolio, but the
Registrant then makes the final decision and selects a portfolio based on all the
information Registrant has about the client. The System also includes an automated
investment engine through which the Registrant manages the client’s portfolio on an
ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is
eligible and elects).
The Registrant does not receive a portion of a wrap fee for our services to clients through
MAPS. Clients do not pay fees to SPT in connection with MAPS, but the Registrant
charges clients a fee for our services as described below under Item 5. Registrant’s fees
are not set or supervised by Schwab. Clients do not pay brokerage commissions or any
other fees to CS&Co as part of MAPS. Schwab does receive other revenues in connection
with MAPS, which are described in the “Compensation to Schwab Under MAPS” section
below.
The Registrant does not pay SPT fees for the Platform so long as it maintain $100 million
in client assets in accounts at CS&Co that are not enrolled in MAPS. If the Registrant
does not meet this condition, then it must pay SPT an annual licensing fee of 0.10% of
the value of its clients’ assets in MAPS. This arrangement presents a conflict of interest,
as it provides an incentive for the Registrant to recommend that clients maintain their
accounts at CS&Co. Notwithstanding, Registrant may generally recommend to its clients
that they maintain investment management accounts at CS&Co. based on the
considerations discussed in Item 12 below, which mitigates but does not eliminate this
conflict of interest.
Clients enrolled in MAPS are limited in the universe of investment options available to
them. For example, the investment options available are limited to ETFs, whereas
Registrant recommends various other types of securities in its other services. MAPS is
designed to provide guidance and professional assistance to individuals who are
beginning the process of accumulating wealth. Clients will have access to their accounts
and a financial interface online but will also have the opportunity to confer with the
Registrant with respect to their account.
Rebalancing
The System will rebalance a client’s account periodically by generating instructions to
CS&Co. to buy and sell shares of funds and depositing or withdrawing funds through the
“Sweep Program”, considering the asset allocation for the client’s investment strategy.
Rebalancing trade instructions can be generated by the System when (i) the percentage
allocation of an asset class varies by a set parameter established by the Registrant, (ii)
Registrant decides to change asset allocation percentages for an investment strategy or
(iii) Registrant decides to change a client’s investment strategy, which could occur, for
example, when a client makes changes to their investment profile or imposes or modifies
restrictions on the management of their account.
Sweep Program
Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held
in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash
Allocation will be a minimum of 4% of an account’s value to be held in cash, and may be
higher, depending on the investment strategy chosen for a client. The Cash Allocation
will be accomplished through enrollment in the Sweep Program, a program sponsored by
CS&Co. By enrolling in MAPS, clients consent to having the free credit balances in their
brokerage accounts at CS&Co. swept into deposit accounts (“Deposit Accounts”) at
Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an
FDIC-insured depository institution that is a Schwab affiliate. The Sweep Program is a
required feature of MAPS. If the Deposit Account balances exceed the Cash Allocation
for a client’s investment strategy, the excess over the rebalancing parameter will be used
to purchase securities as part of rebalancing. If clients request cash withdrawals from
their accounts, this likely will require the sale of fund positions in their accounts to bring
their Cash Allocation in line with the target allocation for their chosen investment
strategy. If those clients have taxable accounts, those sales may generate capital gains (or
losses) for tax purposes. In accordance with an agreement with CS&Co., Schwab Bank
has agreed to pay an interest rate to depositors participating in the Sweep Program that
will be determined by reference to an index.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Registrant may provide
financial planning and related consulting services. Neither the Registrant nor its
investment adviser representatives assist clients with the implementation of any financial
plan, unless they have agreed to do so in writing. The Registrant does not monitor a
client’s financial plan, and it is the client’s responsibility to revisit the financial plan with
the Registrant, if desired.
To the extent requested by a client, Registrant will provide an initial “Needs Assessment”
for such services inclusive of its advisory fee as set forth at Item 5 below. In the event
that a client desires additional financial planning and/or any other related or unrelated
consulting services, the Registrant remains available to provide such services for an
additional fee per the terms and conditions of a separate agreement.
We do not serve as an attorney, accountant, or insurance agency, and no portion of our
services should be construed as legal or accounting services. Accordingly, we do not
prepare estate planning documents, tax returns or sell insurance products. To the extent
requested by a client, we may recommend the services of other professionals for certain
non-investment implementation purpose (i.e. attorneys, accountants, insurance, etc.).
Clients are reminded that they are under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation made by
Registrant or its representatives.
If the client engages any unaffiliated recommended professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional(s)
(i.e. attorney, accountant, insurance agent, etc.), and not the Registrant, shall be
responsible for the quality and competency of the services provided.
Other Investment Advisory Services. Registrant serves as investment adviser to ERISA
pension plans. Registrant is compensated for such services by the pension plan’s third-
party administrator. The Registrant’s compensation is based on a percentage of the asset-
based fee that the pension plan pays to the third party administrator. Registrant may
receive referrals from Paychex, Inc., other third-party administrators, payroll companies,
banks or trust companies, for which it does not pay a referral fee.
Non-Discretionary Service Limitations. Clients that determine to engage the Registrant
on a non-discretionary investment advisory basis must be willing to accept that the
Registrant cannot effect any account transactions without obtaining prior consent to any
such transaction(s) from the client. Therefore, in the event of a market correction during
which the client is unavailable, the Registrant will be unable to affect any account
transactions (as it would for its discretionary clients) without first obtaining the client’s
consent.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and
may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s
age, result in adverse tax consequences). If Registrant recommends that a client roll over
their retirement plan assets into an account to be managed by Registrant, such a
recommendation creates a conflict of interest if Registrant will earn new (or increase its
current) compensation as a result of the rollover. If Registrant provides a
recommendation as to whether a client should engage in a rollover or not, Registrant is
acting as a fiduciary within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. No client is under any obligation to roll over retirement plan assets
to an account managed by Registrant.
Use of Mutual Funds and Exchange Traded Funds. While the Registrant may allocate
investment assets to mutual funds and exchange traded funds (“ETFs”) that are not
available directly to the public, the Registrant may also allocate investment assets to
publicly available mutual funds and ETFs that the client could purchase without engaging
Registrant as an investment adviser. However, if a client or prospective client determines
to purchase publicly available mutual funds or ETFs without engaging Registrant as an
investment adviser, the client or prospective client would not receive the benefit of
Registrant’s initial and ongoing investment advisory services with respect to management
of the asset.
Other mutual funds, such as those issued by Dimensional Fund Advisors (“DFA”), are
generally only available through selected registered investment advisers. Registrant may
allocate client investment assets to DFA mutual funds. Therefore, upon the termination of
Registrant’s services to a client, restrictions regarding transferability and/or additional
purchases of, or reallocation among DFA funds will apply.
Structured Notes. The Registrant may purchase structured notes for client accounts. A
structured note is a financial instrument that combines two elements, a debt security and
exposure to an underlying asset or assets. It is essentially a note, carrying counterparty
risk of the issuer. However, the return on the note is linked to the return of an underlying
asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that
makes structured products unique, as the payout can be used to provide some degree of
principal protection, leveraged returns (but usually with some cap on the maximum
return), and be tailored to a specific market or economic view. In addition, investors may
receive long-term capital gains tax treatment if certain underlying conditions are met and
the note is held for more than one year. Finally, structured notes may also have liquidity
constraints, such that the sale thereof before maturity may be limited.
Unaffiliated Private Investment Funds. Registrant may recommend that certain
qualified clients consider an investment in unaffiliated private investment funds.
Registrant’s role relative to the private investment funds shall be limited to its initial and
ongoing due diligence and investment monitoring services. Registrant’s clients are under
absolutely no obligation to consider or make an investment in a private investment
fund(s).
Risk Factors: Private investment funds generally involve various risk factors, including,
but not limited to, potential for complete loss of principal, liquidity constraints and lack
of transparency, a complete discussion of which is set forth in each fund’s offering
documents, which will be provided to each client for review and consideration. Unlike
liquid investments that a client may own, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that he/she is
qualified for investment in the fund, and acknowledges and accepts the various risk
factors that are associated with such an investment.
Valuation: If Registrant bills an investment advisory fee based upon the value of private
investment funds or otherwise references private investment funds owned by the client on
any supplemental account reports prepared
by Registrant, the value for all private
investment funds owned by the client will reflect the most recent valuation provided by
the fund sponsor. The current value of any private investment fund could be significantly
more or less than the original purchase price or the price reflected in any supplemental
account report.
Variable Annuity Management. The Registrant allocates client investment assets on a
discretionary basis among the investment sub accounts of no load variable annuity
products purchased (potentially through Vanguard, Schwab, or Lincoln Financial) by the
client. The Registrant includes the variable product assets as part of “assets under
management” for the purposes of calculating its annual advisory fee.
Initial Public Offering (IPO) Policy. The Registrant, through its clearing/custodial firm
relationships, may have access to IPO shares for certain securities. Therefore, in certain
limited circumstances and upon client direction, the Registrant may purchase IPOs for
these client accounts. To the extent possible and applicable under the circumstances
(when clients, in the aggregate, have requested more IPO shares than can be obtained by
the Registrant), Registrant will allocate individual client IPO share purchases among
those qualified individual clients expressing a desire to hold a specific IPO on a rotational
basis or some other fair and equitable basis. To the extent possible and applicable under
the circumstances, the Registrant will use reasonable efforts to allocate available IPO
shares on a fair and equitable basis in accordance with the terms and conditions of the
aforementioned policy.
Socially Responsible Investing Limitations. Socially Responsible Investing involves
the incorporation of Environmental, Social and Governance considerations into the
investment due diligence process (“ESG). There are potential limitations associated with
allocating a portion of an investment portfolio in ESG securities (i.e., securities that have
a mandate to avoid, when possible, investments in such products as alcohol, tobacco,
firearms, oil drilling, gambling, etc.). The number of these securities may be limited
when compared to those that do not maintain such a mandate. ESG securities could
underperform broad market indices. Investors must accept these limitations, including
potential for underperformance. Correspondingly, the number of ESG mutual funds and
exchange traded funds are few when compared to those that do not maintain such a
mandate. As with any type of investment (including any investment and/or investment
strategies recommended and/or undertaken by Registrant), there can be no assurance that
investment in ESG securities or funds will be profitable, or prove successful. The
Registrant does not maintain or advocate an ESG investment strategy, but will seek to
employ ESG if directed by a client to do so.
Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin,
Registrant, will advise the client to consider a potential investment in corresponding
exchange traded securities or private funds that provide cryptocurrency exposure. Crypto
is a digital currency that can be used to buy goods and services, but uses an online ledger
with strong cryptography (i.e., a method of protecting information and communications
through the use of codes) to secure online transactions. Unlike conventional currencies
issued by a monetary authority, cryptocurrencies are generally not controlled or regulated
and their price is determined by the supply and demand of their market. Because
cryptocurrency is currently considered to be a speculative investment, Registrant will not
exercise discretionary authority to purchase a cryptocurrency investment for client
accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency
investment. Registrant does not recommend or advocate the purchase of, or investment
in, cryptocurrencies. Registrant considers such an investment to be speculative. Clients
who authorize the purchase of a cryptocurrency investment must be prepared for the
potential for liquidity constraints, extreme price volatility and complete loss of principal.
Separately Managed Account Programs. The Registrant may allocate (and/or
recommend that the client allocate) a portion of a client’s investment assets among
unaffiliated Separately Managed Account programs in accordance with the client’s
designated investment objective(s). In such situations, the Separately Managed Account
Manager shall have day-to-day responsibility for the active discretionary management of
the allocated assets. The Registrant shall continue to render investment advisory services
to the client relative to the ongoing monitoring and review of account performance, asset
allocation and client investment objectives. Factors which the Registrant shall consider in
recommending Separately Managed Account programs include the client’s designated
investment objective(s) as applied to the Separately Managed Account program:
management style, performance, reputation, financial strength, reporting, pricing, and
research.
ByAllAccounts. In conjunction with the services provided by ByAllAccounts, Inc., the
Registrant may also provide periodic comprehensive reporting services, which can
incorporate all of the client’s investment assets including those investment assets that are
not part of the assets managed by the Registrant (the “Excluded Assets”). The
Registrant’s service relative to the Excluded Assets is limited to reporting services only,
which does not include investment implementation. Because the Registrant does not have
trading authority for the Excluded Assets, to the extent applicable to the nature of the
Excluded Assets (assets over which the client maintains trading authority vs. trading
authority designated to another investment professional), the client (and/or the other
investment professional), and not the Registrant, shall be exclusively responsible for
directly implementing any recommendations relative to the Excluded Assets.
Furthermore, the client and/or their other advisors that maintain trading authority, and not
the Registrant, shall be exclusively responsible for the investment performance of the
Excluded Assets. Without limiting the above, the Registrant shall not be responsible for
any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the
event the client desires that the Registrant provide investment management services
(whereby the Registrant would have trading authority) with respect to the Excluded
Assets, the client may engage the Registrant to do so pursuant to the terms and conditions
of the
Investment Advisory Agreement between the Registrant and the client.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Registrant’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated
market conditions/events will occur), Registrant may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, Registrant’s
advisory fee could exceed the interest paid by the client’s money market fund.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from
account transactions or cash deposits be swept into and/or initially maintained in the
custodian’s sweep account. The yield on the sweep account is generally lower than those
available in money market accounts. To help mitigate this issue, Registrant generally
purchases a higher yielding money market fund available on the custodian’s platform
with cash proceeds or deposits, unless Registrant reasonably anticipates that it will utilize
the cash proceeds during the subsequent 30-day period to purchase additional
investments for the client’s account. Exceptions and/or modifications can and will occur
with respect to all or a portion of the cash balances for various reasons, including, but not
limited to, the amount of dispersion between the sweep account and a money market
fund, an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in
Registrant’s operations and result in the unauthorized acquisition or use of clients’
confidential or non-public personal information. Clients and Registrant are nonetheless
subject to the risk of cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational damage to respond
to regulatory obligations, other costs associated with corrective measures, and loss from
damage or interruption to systems. Although Registrant has established its systems to
reduce the risk of cybersecurity incidents from coming to fruition, there is no guarantee
that these efforts will always be successful, especially considering that Registrant does
not directly control the cybersecurity measures and policies employed by third-party
service providers. Clients could incur similar adverse consequences resulting from
cybersecurity incidents that more directly affect issuers of securities in which those
clients invest, broker-dealers, qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial institutions.
Disclosure Statement. A copy of the Registrant’s written Brochure and Client
Relationship Summary, as set forth on Part 2A of Form ADV and Form CRS
respectively, shall be provided to each client prior to, or contemporaneously with, the
execution of the
Investment Advisory Agreement, Financial Planning Agreement or the
Investment Consulting Agreement.
The National Association of Personal Financial Advisors. Registrant receives referrals
from The National Association of Personal Financial Advisors (“NAPFA”). While
Registrant pays fees to NAPFA, such fees are not directly related to the number of clients
referred to Registrant.
WomenCertified Inc. The Registrant is a recipient of the 2021 Women’s Choice
Award®. The Women’s Choice Award® Financial Advisor program was created by
WomenCertified Inc., the Voice of Women, in an effort to help women make smart
financial choices. The Women’s Choice Award Financial Program is based on 17
objective criteria associated with providing quality service to women clients, such as
educational and professional credentials, experience, and a favorable regulatory history,
among other factors, including letters of validation and background check. Financial
advisors do not pay a fee to qualify for the program. All qualified advisors are listed on
womenschoiceaward.com. Once qualified, financial advisors may purchase additional
marketing collateral such as seal usage, enhanced listing or promotional products. The
inclusion of a financial advisor within the WCA Financial Advisor network should not be
construed as an endorsement of the financial advisor by WomenCertified Inc. or its
partners and affiliates and is no guarantee of quality of services provided to clients or
future investment success.
Women’s Choice Award® Financial Advisors and Firms represent less than 1% of
financial advisors in the U.S. As of December 31, 2021, of the 603 considered for the
Women’s Choice Award, 221 were named Women’s Choice Award Financial
Advisors/Firms.
The Registrant receives referrals and recommendations from WomenCertified Inc. as a
result of receiving this award.
Fee-Only Network Registrant receives referrals from Fee-Only Network.com in
collaboration with National Association of Personal Financial Advisors (“NAPFA”).
While Registrant pays fees to Fee-Only Network.com, such fees are not directly related
to the number of clients referred to Registrant. Investors use this free service to find local
advisors, learn more about financial advisors and to view documentation for advisors'
credentials and business practices.
DFA Advisor Listing The Registrant’s representatives are approved to provide
Dimensional Funds Advisors (“DFA”) and therefore eligible to be included on the DFA
Advisor Listing. The Registrant does not pay a fee for their DFA Advisor Listing
membership, but registered representatives have completed specialized investment
education to offer DFA funds. The DFA Advisor Listing allows the public to access local
advisors that have completed the requirements of DFA and can offer their mutual funds
to interested investors.
FMG Suite
FMG Suite is an automated marketing content platform and lead generation system that
allows advisors to create an engaging digital experience for their clients and prospects;
from newsletters, email, website, and social media. Proprietary technology captures
potential lead data every time an advisors’ content is shared and opened. The Registrant
pays a monthly service fee to participate with this platform.
Wealthramp
Wealthramp is a personalized and unbiased online financial referral service, connecting
investors with vetted fiduciary advisors who best match an individual's investing
priorities. Wealthramp is a registered investment advisor and as such, they are set up to
receive fees from the advisors in their network. The advisor shares a portion of the fee
they have received from investors. Advisors agree not to increase their fees to
compensate Wealthramp. Advisors in our network do not pay Wealthramp for making an
introduction, they only pay Wealthramp after the prospective client decides to hire them.
Investors only pay the advisor once they have agreed to work with him or her. Investors
will pay your advisor directly, based on their agreement and the advisor will pay twenty-
five percent to Wealthramp.
Finplicity Network
One or more of Registrant’s representatives are approved members of the Finplicity
Networ
k on KentOnMoney.com The Registrant does not pay a fee for their membership.
Finplicity Network allows
KentOnMoney.com users to access personal finance
information and local advisors vetted by Finplicity and Dr. Kent Smetters.
SmartAsset
SmartAsset offers free web-based information and personalized tools which also help
investors find local prescreened financial advisors via SmartAsset Advisors, LLC (“SA”).
SA, a wholly owned subsidiary of Financial Insight Technology, is a registered
investment advisor under the Securities and Exchange Commission. SA does not manage
client funds or hold custody of assets. The Registrant is an unaffiliated firm that receives
referrals from SmartAsset Advisors, LLC in exchange for a flat fee per referral.
ABP Active Trader. In addition to the investment management services provided above,
the Registrant may also provide administrative and reporting services for certain clients
who have established a separate account at Schwab (the "ABP Account"). Unlike the
accounts that the Registrant may manage for the client, in the ABP Account, the client
will retain exclusive responsibility for all trading activity and account performance. The
Registrant shall not provide any investment implementation, monitoring, review or
advisory services with respect to the ABP Account. The terms and conditions for the
Registrant's ABP services are set forth in a separate written agreement between the
Registrant and the client.
In the event that the ABP Account suffer losses (regardless of amount) or encounters any
other problems which are not the direct result of the Registrant's failure to provide its
administrative services, the client acknowledges and agrees that the Registrant shall bear
no corresponding financial responsibility.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2022, the Registrant had $993,000,000 in assets under management
on a discretionary basis and $491,000,000 in assets under management on a
non-discretionary basis.